Interpretation ID: aiam3139
Manager - Research & Development
Bajaj Auto Limited
Bombay Poona Road
Akurdi - Poona - 411 035
India;
Dear Mr. Keshav: This is in reply to your letter of September 2, 1979, to Franci Armstrong asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108. SAE Standard J588e August 1970 is the referenced standard for turn signal lamps. Paragraph 4.2 of J588e requires that as mounted on the vehicle 'The optical axis (filament center) of the front turn signal lamp shall be at least 4 inches from the inside diameter of the retaining ring of the headlamp unit providing the lower beam'. You mentioned that on some motorcycles sold in the United States this requirement is satisfied only with the handlebar in the straight ahead position but not when turned to the full lock position. You asked whether this complies with Standard No. 108.; Table IV specifies that the minimum edge to edge separation between th headlamp and turn signal lamp on motorcycles is 4 inches. Most manufacturers have interpreted this requirement to mean that the separation is permanent, and have supplied turn signals that are mounted stationary with the headlamp, and that turn with it so that the separation distance is maintained. Therefore, the configuration you describe would not comply with Standard No. 108 because Federal requirements for location and mounting of lighting equipment are intended to apply to a vehicle under all its operating conditions.; Sincerely, Frank Berndt, Chief Counsel